Justia Civil Rights Opinion Summaries

Roderick Barnes III was convicted by a jury of three counts of attempted murder, three counts of attempted robbery, and three counts of assault with a firearm. The jury also found that Barnes personally discharged a firearm causing great bodily injury and that he participated in a criminal street gang, committing the crimes for the benefit of the gang. Barnes was sentenced to 70 years to life in prison.Barnes appealed, arguing that the trial court erred in overruling his objection to the prosecutor’s use of a peremptory challenge against a Black prospective juror, failing to instruct the jury with CALCRIM No. 332, and that there was insufficient evidence to support the gang participation conviction and enhancements. The People conceded the latter two points but argued that the gang-related offenses could be retried.The California Court of Appeal, Fourth Appellate District, Division One, reviewed the case. The court found that the trial court erred in overruling Barnes’s objection to the peremptory challenge. The court determined that the prosecutor’s reasons for striking the juror were not valid and that the trial court improperly considered reasons not stated by the prosecutor. The court also found that substantial evidence did not support the gang participation conviction and enhancements, as the prosecution failed to provide a sufficient foundation for the expert’s opinion that the murder of P.M. commonly benefited the gang.The Court of Appeal reversed the judgment in its entirety and remanded the case for a new trial on counts 1 through 9. The court held that the prosecution could not retry Barnes for the gang participation offense or the gang enhancements due to insufficient evidence. View "People v. Barnes" on Justia Law

Henry Washington, a state prisoner, alleged that prison guard T.S. Oswald sexually assaulted him twice, once in 2013 and again in 2015. During the first incident, Washington claimed that Oswald and another guard handcuffed him, fondled him, and attempted to insert a nightstick into his rectum, causing him to bleed. In the second incident, Oswald allegedly fondled Washington and attempted to insert his finger into Washington's rectum while escorting him back to his cell.Washington sued Oswald under 42 U.S.C. § 1983 for cruel and unusual punishment. The jury found in favor of Washington, awarding him $20,000 in compensatory damages and $25,000 in punitive damages for the 2013 assault, and $20,000 in compensatory damages and $200,000 in punitive damages for the 2015 assault. Oswald moved for judgment as a matter of law or a new trial, arguing insufficient evidence and excessive punitive damages. The United States District Court for the Western District of Pennsylvania denied these motions.The United States Court of Appeals for the Third Circuit reviewed the case. The court held that there was sufficient evidence for the jury to find Oswald liable for both assaults. The court also upheld the punitive damages, finding them not excessive under the Due Process Clause. The court noted that Oswald's actions were highly reprehensible, the punitive damages were proportionate to the harm caused, and the awards were consistent with those in comparable cases. The court affirmed the District Court's decision, maintaining the jury's awards. View "Washington v. Gilmore" on Justia Law

The case involves a defendant charged with multiple first-degree sexual offenses against a victim, J, who has an intellectual disability. The defendant did not dispute J's disability but argued that she was capable of consenting to the sexual acts. The trial court denied the defendant's motion for judgment of acquittal, and a jury convicted him of various charges. The defendant appealed, arguing that the state failed to prove that J's disability rendered her incapable of appraising the nature of her conduct.The Oregon Court of Appeals, in a divided decision, reversed the trial court's judgment, concluding that the evidence was insufficient to show that J was incapable of understanding the sexual nature of the conduct or exercising judgment to consent to it. The state petitioned for review, challenging the Court of Appeals' interpretation and application of the relevant statutes.The Oregon Supreme Court reviewed the case, focusing on the interpretation of ORS 163.305(3) and ORS 163.315(1)(b), which define when a person is incapable of consenting to a sexual act due to a mental defect. The court clarified that to be capable of consent, a person must be able to appraise the nature of their conduct, which involves exercising judgment and making choices based on an understanding of the conduct's significance. The court emphasized that the state must prove that the person's intellectual disability prevented them from appraising the nature of the conduct at the time of the alleged offense.The Oregon Supreme Court concluded that the evidence presented at trial was sufficient to allow a rational jury to find that J's intellectual disability rendered her incapable of appraising the nature of her conduct. Therefore, the trial court did not err in denying the defendant's motion for judgment of acquittal. The court reversed the decision of the Court of Appeals and affirmed the trial court's judgment in part, but reversed the conviction on Count 5 due to a nonunanimous jury verdict, remanding for further proceedings. View "State v. Wallace" on Justia Law

Tam Steven Nguyen committed various crimes at the age of 22 and was convicted in 2003 of attempted murder, kidnapping, and assault with a firearm. The jury also found true firearm allegations. He was sentenced to a determinate term of 14 years, an indeterminate term of 25 years to life, and a life term with the possibility of parole. While incarcerated, Nguyen earned various credits, including good conduct and educational merit credits. His minimum eligible parole date (MEPD) is set for February 2036, and his youth parole eligible date (YPED) is set for October 2026.Nguyen petitioned the trial court for a writ of habeas corpus in 2022, arguing that he should be allowed to use all earned credits to advance his YPED, not just educational merit credit. The trial court denied his petition. Nguyen then petitioned the California Court of Appeal, which summarily denied the petition. The California Supreme Court granted review, ordered the appellate court to vacate its order, and issue an order to show cause.The California Court of Appeal reviewed the case and held that Nguyen's right to equal protection was not violated. The court found that youth and nonyouth offenders are not similarly situated for the purposes of the challenged regulations, as youth offenders have two parole eligibility dates (MEPD and YPED) while nonyouth offenders have only one (MEPD). The court also determined that there is a rational basis for the regulation, as it aligns with the legislative intent to provide youth offenders with a meaningful opportunity for release while maintaining a relatively fixed YPED. Consequently, the court denied Nguyen's petition for writ of habeas corpus. View "In re Nguyen" on Justia Law

Joseph Corcoran was convicted of four murders by an Allen County jury, and the judge sentenced him to death as recommended by the jury. Corcoran has been involved in extensive litigation over the past 25 years, including multiple decisions from the Indiana Supreme Court and the United States Supreme Court, regarding the constitutionality of his execution. Corcoran has expressed his desire to accept his conviction and sentence, stating that he does not wish to pursue further legal challenges.The Allen Superior Court initially sentenced Corcoran to death, and the Indiana Supreme Court remanded for resentencing due to the consideration of non-statutory aggravating factors. Upon resentencing, the death sentence was reimposed and affirmed by the Indiana Supreme Court. Corcoran chose not to pursue post-conviction relief, leading to competency proceedings initiated by the State Public Defender, who argued that Corcoran was incompetent to waive post-conviction remedies. The trial court and the Indiana Supreme Court found Corcoran competent. Corcoran later filed an untimely petition for post-conviction relief, which was dismissed.The Indiana Supreme Court reviewed the case and denied the State Public Defender's motions to file successive petitions for post-conviction relief and to stay the execution. The court held that Corcoran is competent to waive post-conviction remedies and that the State Public Defender lacks standing to file the petitions without Corcoran's authorization. Additionally, the court found no reasonable possibility that Corcoran is entitled to relief, as the claims presented were procedurally defaulted and previously addressed. The court concluded that Corcoran has a rational understanding of his execution and the reasons for it, and thus, denied the motions for a stay of execution. View "Corcoran v. State" on Justia Law

Andre Louis Keller drove to a permanent immigration checkpoint where a Customs & Border Protection (CBP) canine alerted to his vehicle. Upon searching, agents found an alien unlawfully present in the United States concealed under luggage. Keller conditionally pleaded guilty and appealed the district court’s denial of his motion to suppress the evidence found in the vehicle.The United States District Court for the Southern District of Texas held a hearing on Keller’s motion to suppress. Testimonies were provided by CBP Agent Jesse Sandoval, Matthew B. Devaney from CBP’s Canine Academy, and Andre Falco Jimenez, a private police dog trainer. The district court denied Keller’s motion, leading to his conditional guilty plea. Keller was sentenced to 20 months in prison and 3 years of supervised release. He then appealed the suppression ruling.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court held that stopping a vehicle for brief questioning at a permanent immigration checkpoint is not a Fourth Amendment search and does not require probable cause. The court found that the canine’s alert provided probable cause to search Keller’s vehicle. The court also concluded that the canine’s actions did not constitute an unlawful search and that the district court did not err in its ruling. The Fifth Circuit affirmed the district court’s denial of Keller’s motion to suppress. View "United States v. Keller" on Justia Law

C.H., an eleven-year-old, was sexually exploited by a stranger on Omegle.com, an online platform that connects users in video chatrooms. The stranger, referred to as John Doe, threatened C.H. into creating child pornography. C.H.'s parents sued Omegle.com LLC, alleging violations of 18 U.S.C. § 2255 (Masha’s Law) for knowingly possessing child pornography and the Trafficking Victims Protection Reauthorization Act for knowingly benefiting from a sex trafficking venture.The United States District Court for the Middle District of Florida dismissed the claims, citing section 230 of the Communications Decency Act, which protects providers of interactive computer services from being treated as the publisher or speaker of user-provided information. The court also found that the sex trafficking claim did not meet the Fight Online Sex Trafficking Act (FOSTA) exception to section 230 because C.H.'s parents did not allege that Omegle.com had actual knowledge of benefiting from sex trafficking.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court held that C.H.'s parents did not state a claim under Masha’s Law because they failed to allege that Omegle.com knowingly possessed or accessed child pornography. The court also held that the FOSTA exception to section 230 requires actual knowledge of sex trafficking, not just constructive knowledge. Since C.H.'s parents did not plausibly allege that Omegle.com had actual knowledge of the sex trafficking incident involving C.H., the court affirmed the district court's dismissal of the claims. View "M.H., et al. v. Omegle.com LLC" on Justia Law

One night, Officer Devosie Jones of the City of Remerton Police Department attempted to stop a black Cadillac with one headlight. The car did not stop, leading to a high-speed chase that ended when the Cadillac crashed into a tree. Quinton Simmons was found trying to exit the car and was arrested. Officers found narcotics and a firearm in the vehicle. Simmons was charged with possession of methamphetamine with intent to distribute, possession of a firearm by a convicted felon, and possession of a firearm in furtherance of a drug trafficking crime. He pleaded not guilty, claiming he was kidnapped and framed by a gang member who fled the scene.The United States District Court for the Middle District of Georgia denied Simmons's Batson challenge, accepting the government's race-neutral reasons for striking three black jurors. During the trial, the court allowed the government to play a brief segment of a body camera video but denied Simmons's request to play additional clips during closing arguments, as they had not been shown during the evidence phase. The jury found Simmons guilty on all counts.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court held that the district court did not abuse its discretion in limiting the scope of closing arguments, as Simmons had the opportunity to present the video clips during the trial but chose not to. The court also found no error in the district court's denial of the Batson challenge, as Simmons failed to make a prima facie case of racial discrimination, and the government's race-neutral explanations were credible. The Eleventh Circuit affirmed the district court's judgment. View "United States v. Simmons" on Justia Law

Wayne Lozier, Jr., a licensed bounty hunter in Louisiana, traveled to Missouri to detain a fugitive, R.C., who had failed to appear for her court date in Louisiana. Lozier entered a residence in Missouri, handcuffed R.C., and transported her towards Mississippi. During this time, the residence owner alerted law enforcement, leading to an investigation by Officer Jeffrey Atkins. Lozier was found to have violated Missouri laws by not being licensed in Missouri and failing to notify local law enforcement before apprehending R.C.A federal grand jury indicted Lozier for kidnapping and conspiracy to kidnap. Lozier moved to dismiss the indictment, arguing his actions were lawful as an agent of a bail bondsman. The United States District Court for the Eastern District of Missouri denied these motions, stating Lozier's arguments were factual challenges. At trial, Lozier admitted to the Missouri law violations but contended his actions were standard fugitive apprehension. He objected to a jury instruction that he claimed deprived the jury of deciding whether his actions were unlawful. The jury found Lozier guilty on both counts, and he was sentenced to 120 months on each count, to run concurrently.The United States Court of Appeals for the Eighth Circuit reviewed the case and found that the jury instruction (Instruction 16) created a conclusive presumption that Lozier acted unlawfully by violating Missouri law, thus removing the jury's ability to consider justification or excuse. This violated Lozier's due process rights. The court held that this error was not harmless and vacated Lozier's convictions, remanding the case for a new trial. View "United States v. Lozier" on Justia Law

Tam Steven Nguyen committed various crimes at the age of 22 and was convicted in 2003 of attempted murder, kidnapping, and assault with a firearm. He was sentenced to a determinate term of 14 years, an indeterminate term of 25 years to life, and a life term with the possibility of parole. While incarcerated, Nguyen earned various credits, including good conduct and educational merit credits. These credits were applied to his minimum eligible parole date (MEPD) and youth parole eligible date (YPED), respectively.Nguyen petitioned the trial court for a writ of habeas corpus in 2022, arguing that he should be able to use all types of credits to advance his YPED, not just educational merit credit. The trial court denied his petition. Nguyen then petitioned the California Court of Appeal, which summarily denied the petition. The California Supreme Court granted review, ordered the appellate court to vacate its order, and issued an order to show cause.The California Court of Appeal reviewed the case and held that Nguyen's right to equal protection was not violated. The court found that youth and nonyouth offenders are not similarly situated for the purposes of the challenged regulations, as youth offenders have two parole eligibility dates (MEPD and YPED) while nonyouth offenders have only one (MEPD). The court also determined that there is a rational basis for the regulation that limits the types of credits that can advance a youth offender's YPED, as it aligns with the legislative intent to provide a fixed and relatively stable parole eligibility date for youth offenders. Consequently, the court denied Nguyen's petition for writ of habeas corpus. View "In re Nguyen" on Justia Law